EIN: 770411194
UEI: DW2CGBKX1188
Audited by: Vasquez & Company LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 29, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 15, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 15, 2026 (78 days from today).
What is a management decision? →During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025
Show full finding ▾Hide full finding ▴Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 5. Public Health Institute (PHI) Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Activities Allowed or Unallowed Criteria: Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements. 2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger). In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended. Condition: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025
Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Finding: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025
2023-001
During our testing of 24 reporting samples, we identified two (2) instances wherein Quarterly Expenditure Reports related to the grant of Council on American Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), including the evidence of submission (e.g. confirmation emails or system-generated receipts), were not available for review. Cause: Management indicated that the reports and supporting documentation could not be located. Additionally, the staff previously responsible for preparing and submitting these reports is no longer with the Organization. Effect: The absence of documented evidence may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements. Questioned Cost: None Recommendation: We recommend that CAIR-CA finalize and consistently implement a formal process for retaining submitted grant reports and supporting documentation. This process should include keeping submission confirmations, such as email receipts, portal confirmations, or screenshots, as well as retaining copies of the submitted reports, to provide clear evidence of timely and accurate submission for all required reports. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already implemented reporting procedures to include the retention of submission confirmations as part of its grant documentation. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: October 31, 2025
Show full finding ▾Hide full finding ▴Finding No.2024-002: Maintain Supporting Documentation for Required Federal Reports Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entity: California Rural Legal Assistance Foundation Federal Award Number: Not available in the contract Federal Award Year: November 1, 2022 – March 31, 2025 Compliance Requirement: Reporting Criteria or Specific Requirements: The Compliance Supplement requires that Quarterly Expenditure Reports be submitted for this program. Additionally, 2 CFR 200.334 requires non-federal entities to retain financial records, supporting documentation, and all other pertinent records to substantiate federal award reporting. Condition: During our testing of 24 reporting samples, we identified two (2) instances wherein Quarterly Expenditure Reports related to the grant of Council on American Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), including the evidence of submission (e.g. confirmation emails or system-generated receipts), were not available for review. Cause: Management indicated that the reports and supporting documentation could not be located. Additionally, the staff previously responsible for preparing and submitting these reports is no longer with the Organization. Effect: The absence of documented evidence may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements. Questioned Cost: None Recommendation: We recommend that CAIR-CA finalize and consistently implement a formal process for retaining submitted grant reports and supporting documentation. This process should include keeping submission confirmations, such as email receipts, portal confirmations, or screenshots, as well as retaining copies of the submitted reports, to provide clear evidence of timely and accurate submission for all required reports. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already implemented reporting procedures to include the retention of submission confirmations as part of its grant documentation. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: October 31, 2025
Finding No.2024-002: Maintain Supporting Documentation for Required Federal Reports Finding: During our testing of 24 reporting samples, we identified two (2) instances wherein Quarterly Expenditure Reports related to the grant of Council on American Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), including the evidence of submission (e.g. confirmation emails or system-generated receipts), were not available for review. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already implemented reporting procedures to include the retention of submission confirmations as part of its grant documentation. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: October 31, 2025.
2023-002
The single audit reporting package for the year ended December 31, 2023, was submitted by CAIR-CA in August 2025. CAIR-CA also failed to complete its financial and single audit for the year ended December 31, 2024 within the required nine month deadline under 2 CFR 200.512. As of September 30, 2025, no single audit report has been issued or filed, resulting in noncompliance with federal audit requirements. Cause: The year ended December 31, 2023, represented CAIR-CA’s first year undergoing a single audit, with 2024 being its second. During this initial implementation period, management was in the process of aligning its internal processes with applicable federal reporting requirements, including FAC submission protocols and deadlines. As part of this transition, formalized procedures to support timely submission were established and refined. Effect: Delays in submitting the single audit reporting package result in noncompliance with federal requirements and may increase scrutiny from federal agencies or affect the timing of future funding. Questioned Cost: None Recommendation: We recommend that management continue to enhance its processes related to single audit compliance and formalize policies and procedures to support timely submission. This should include establishing clear timelines, assigning responsibility for monitoring key deadlines, and implementing a process to track submission status to the FAC. These steps will help promote timely and accurate submissions in the future reporting periods. Views of Responsible Officials and Corrective Action Plan: Management has developed and implemented corrective actions to address this finding. As of January 1, 2026, formal procedures for FAC submission have been established, including defined roles, internal deadlines, and review protocols. A compliance tracking system has been implemented to monitor key reporting deadlines, and staff have received training on federal requirements. Management will continue to monitor adherence to these procedures to ensure timely submission in future reporting periods. Implementation date: January 1, 2026
Show full finding ▾Hide full finding ▴Finding No.2024-003: Noncompliance with Annual Financial Statements Audit and Single Audit Submission Requirements Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 5. Public Health Institute (PHI) 6. License to Freedom Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Reporting Criteria: California Nonprofit Integrity Act of 2004 requires nonprofit organizations to obtain an annual independent audit and must make the audited financial statements available to the California Attorney General no later than 9 months after the close of the fiscal year. Title 2 CFR § 200.512(a)(1) requires non-federal entities to submit the single audit reporting package, including the Data Collection Form (SF‑SAC) and the auditor’s reports, to the Federal Audit Clearinghouse (FAC) within the earlier of (i) 30 calendar days after receipt of the auditor’s reports, or (ii) nine (9) months after the end of the audit period. Condition: The single audit reporting package for the year ended December 31, 2023, was submitted by CAIR-CA in August 2025. CAIR-CA also failed to complete its financial and single audit for the year ended December 31, 2024 within the required nine month deadline under 2 CFR 200.512. As of September 30, 2025, no single audit report has been issued or filed, resulting in noncompliance with federal audit requirements. Cause: The year ended December 31, 2023, represented CAIR-CA’s first year undergoing a single audit, with 2024 being its second. During this initial implementation period, management was in the process of aligning its internal processes with applicable federal reporting requirements, including FAC submission protocols and deadlines. As part of this transition, formalized procedures to support timely submission were established and refined. Effect: Delays in submitting the single audit reporting package result in noncompliance with federal requirements and may increase scrutiny from federal agencies or affect the timing of future funding. Questioned Cost: None Recommendation: We recommend that management continue to enhance its processes related to single audit compliance and formalize policies and procedures to support timely submission. This should include establishing clear timelines, assigning responsibility for monitoring key deadlines, and implementing a process to track submission status to the FAC. These steps will help promote timely and accurate submissions in the future reporting periods. Views of Responsible Officials and Corrective Action Plan: Management has developed and implemented corrective actions to address this finding. As of January 1, 2026, formal procedures for FAC submission have been established, including defined roles, internal deadlines, and review protocols. A compliance tracking system has been implemented to monitor key reporting deadlines, and staff have received training on federal requirements. Management will continue to monitor adherence to these procedures to ensure timely submission in future reporting periods. Implementation date: January 1, 2026
Finding No.2024-003: Noncompliance with Annual Financial Statements Audit and Single Audit Submission Requirements Finding: The single audit reporting package for the year ended December 31, 2023, was submitted by CAIR-CA in August 2025. CAIR-CA also failed to complete its financial and single audit for the year ended December 31, 2024 within the required nine month deadline under 2 CFR 200.512. As of September 30, 2025, no single audit report has been issued or filed, resulting in noncompliance with federal audit requirements. Views of Responsible Officials and Corrective Action Plan: Management has developed and implemented corrective actions to address this finding. As of January 1, 2026, formal procedures for FAC submission have been established, including defined roles, internal deadlines, and review protocols. A compliance tracking system has been implemented to monitor key reporting deadlines, and staff have received training on federal requirements. Management will continue to monitor adherence to these procedures to ensure timely submission in future reporting periods. Implementation date: January 1, 2026
FAC accepted this audit on September 11, 2025 — management decision was due March 11, 2026.
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts. Cause: This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant. Effect: Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures. Questioned Cost: None Recommendation: We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: November 20, 2025
Show full finding ▾Hide full finding ▴2023-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1 Federal Award Year: 8/1/2022 to 3/31/2025 Compliance Requirement: Activities Allowed or Unallowed Criteria: Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements. 2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger). In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended. Condition: During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts. Cause: This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant. Effect: Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures. Questioned Cost: None Recommendation: We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: November 20, 2025
Corrective Actions Taken or Planned Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: November 20, 2025
During our testing of 10 reporting samples, we identified two instances wherein CAIR-CA did not retain confirmation or proof of submission (e.g., email receipts, submission confirmations from the federal portal) for demographic data reports submitted under the contract between CRLAF and Council on American-Islamic Relations, CAIR-SFBA. Additionally, we were informed that demographic data updates are entered directly into the Afghan Legal Services Project (ALSP) Reporting Database. As a result, no copies of submitted reports were generated or retained for review. Cause: CAIR-CA has not established a formal process requiring the retention of submitted reports and confirmations of submission as part of its grant reporting procedures. Effect: The absence of documentation may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements. Questioned Cost: None Recommendation: We recommend that CAIR-CA implement a standardized process of retaining copies of documentation of report submissions. This process should include saving submission confirmations for all required federal reports, such as email receipts, portal confirmations, or screenshots, as evidence of timely and accurate submission. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025.
Show full finding ▾Hide full finding ▴Finding No.2023-002: Maintain Supporting Documentation for Federal Report Submissions Assistance Listing Number: 93.566 Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entity: California Rural Legal Assistance Foundation Federal Award Number: Not available in the contract Federal Award Year: October 1, 2022 – October 31, 2024 Compliance Requirement: Reporting Criteria or Specific Requirements: Section 6 of the Memorandum of Understanding between California Rural Legal Assistance Foundation (CRLAF) and the Council on American-Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), outlines the subrecipient's reporting requirements for demographic data. a. The subgrantee shall regularly update a reporting database, the “ALSP Reporting Database”, shared with CRLAF and California Department of Social Services (CDSS), that quantitatively describes the services provided under this project. The subgrantee shall collect and report in this database the following information, without disclosing personally identifiable information or other confidential information: • Number of individuals provided legal assistance • For immigration legal services: case type • For non-legal services: service type • Case outcomes, as feasibly possible • General demographic information, reported anonymously, about individuals served: age, language, nationality, and county of residence b. The deadline to update the reporting database with information from individuals served in each month of the grant term shall be the 5th day of the following month. Condition: During our testing of 10 reporting samples, we identified two instances wherein CAIR-CA did not retain confirmation or proof of submission (e.g., email receipts, submission confirmations from the federal portal) for demographic data reports submitted under the contract between CRLAF and Council on American-Islamic Relations, CAIR-SFBA. Additionally, we were informed that demographic data updates are entered directly into the Afghan Legal Services Project (ALSP) Reporting Database. As a result, no copies of submitted reports were generated or retained for review. Cause: CAIR-CA has not established a formal process requiring the retention of submitted reports and confirmations of submission as part of its grant reporting procedures. Effect: The absence of documentation may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements. Questioned Cost: None Recommendation: We recommend that CAIR-CA implement a standardized process of retaining copies of documentation of report submissions. This process should include saving submission confirmations for all required federal reports, such as email receipts, portal confirmations, or screenshots, as evidence of timely and accurate submission. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025.
Corrective Actions Taken or Planned Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025.
During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses. Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked. Cause: CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges. Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program. Effect: These control deficiencies resulted in the overbilling of federal funds. Questioned Cost: $1,417 Recommendation: To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards. Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements. In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025
Show full finding ▾Hide full finding ▴Finding No.2023-003: Improve Controls Over Expense Reporting and Payroll Charges Assistance Listing Number: 93.566 Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entity: 1. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 2. California Department of Social Services (CDSS) Federal Award Number: 1. Not available in the contract 2. ACS22-05-CAIR-A1 Federal Award Year: 1. February 1, 2023 – March 31, 2024 2. November 1, 2022 – March 31, 2025 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirements: In accordance with 2 CFR 200.403 and 200.405, costs charged to a federal award must be necessary, reasonable, and allocable. In addition, 2 CFR 200.430 Compensation-personal services, provides that compensation for personal services must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses. Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked. Cause: CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges. Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program. Effect: These control deficiencies resulted in the overbilling of federal funds. Questioned Cost: $1,417 Recommendation: To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards. Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements. In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025
Corrective Actions Taken or Planned Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements. In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025
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